In addition to the 600 MHz auction, Dish said it planned to bid in the FCC’s AWS-3 auction scheduled for later this year. Dish advised the Commission to adopt separate bidding eligibility, activity waivers, and auction stopping rules for the 1695-1710 MHz licenses and the 1755-1780/2155-2180 MHz band licenses available in that auction.

Besides outlining its auction plans and suggestions, Dish commented on the large mergers the FCC is currently considering. It stressed that the Comcast-Time Warner merger should be denied over competition concerns in the broadband and video markets.

“High-capacity cable broadband connections are the lifeblood of over-the-top (“OTT”) video services,” Dish wrote in the filing. “Among other things, the combined company would have an increased incentive and ability to leverage its control over the broadband pipe to undermine these services.”

Dish further explained that the combined company would have three “choke points in the broadband pipe” it could use against competing OTT video services: “the last mile ‘public Internet’ channel to the consumer; the interconnection point; and any managed or specialized service channels, which can act as high-speed lanes and squeeze the capacity of the public Internet portion of the pipe”

Dish also set its sights on AT&T’s $49 billion bid to acquire DirecTV, saying that combined company would have the “market power to leverage programming content, to the potential detriment of consumers.”